RS-05-111, Additional Information Supporting the Request for License Amendment Related to Application of Alternative Source Term

Additional Information Supporting the Request for License Amendment Related to Application of Alternative Source Term

ML052430196
Person / Time
Site:	Clinton
Issue date:	08/19/2005
From:	Jury K AmerGen Energy Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-05-111
Download: ML052430196 (40)

Text

ArnerGen Energy Company, LLC www.exeloncorp.com AmerGena An Exelon Company 4300 Winfield Road Warrenville, IL 60555 RS-05-1 11 10 CFR 50.90 August 19, 2005 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461

Subject:

Additional Information Supporting the Request for License Amendment Related to Application of Alternative Source Term

References:

1. Letter from Michael J. Pacilio (AmerGen Energy Company, LLC) to U. S. NRC, "Request for License Amendment Related to Application of Alternative Source Term," dated April 3, 2003

2. Letter from Keith R. Jury (AmerGen Energy Company, LLC) to U. S.

NRC, "Additional Information Supporting the Request for License Amendment Related to Application of the Alternative Source Term,"

dated December 23, 2003

3. Letter from Keith R. Jury (AmerGen Energy Company, LLC) to U. S.

NRC, "Additional Information Supporting the Request for License Amendment Related to Application of Alternative Source Term," dated December 9, 2004

4. Letter from Keith R. Jury (AmerGen Energy Company, LLC) to U. S.

NRC, "Additional Information Supporting the Request for License Amendment Related to Application of Alternative Source Term," dated December 17, 2004

5. Letter from Keith R. Jury (AmerGen Energy Company, LLC) to U. S.

NRC, "Additional Information Supporting the Request for License Amendment Related to Application of the Alternative Source Term,"

dated March 30, 2005

6. Letter from Kahtan N. Jabbour (U. S. NRC) to Christopher M. Crane (AmerGen Energy Company, LLC), "Clinton Power Station, Unit 1 -

Request for Additional Information Re: Application of Alternative Source Term Methodology (TAC No. MB8365)," dated July 26, 2005

August 19, 2005 U. S. Nuclear. Regulatory-Commission Page 2 In Reference 1, AmerGen Energy Company, LLC (AmerGen) submitted a request for a change to Appendix A, Technical Specifications (TS), of Facility Operating License No.

NPF-62 for Clinton Power Station (CPS). Specifically, the proposed change is requested to support application of an alternative source term (AST) methodology, in accordance with 10 CFR 50.67, "Accident source term," with the exception that Technical Information Document (TID) 14844, "Calculation of Distance Factors for Power and Test Reactor Sites," will continue to be used as the radiation dose basis for equipment qualification.

AmerGen provided additional information in References 2, 3, 4, and 5 to support the NRC's review of the proposed change.

In Reference 6, the NRC requested additional information that is needed to complete review of the proposed change. These requests were concerned with the AmerGen use of the deposition methodology from AEB-98-03, "Assessment of Radiological Consequences for the Perry Pilot Plant Application Using the Revised (NUREG-1465) Source Term." The NRC believes this methodology was nonconservative. Therefore, to resolve the NRC concern with the deposition methodology, AmerGen has revised the Loss of Coolant Accident (LOCA) analysis. Attachment 1 to this letter provides the requested information.

In addition, the Main Steam Line Break accident analysis has been revised to provide additional margin and to address cesium releases. Copies of the revised calculations are provided on the enclosed CD-ROM.

AmerGen has developed a set of tables documenting the changes in parameters and methods used in each version of the supporting calculations. These tables are provided as . A summary of the revised analysis results is also included in Attachment 2.

The tables provided in Attachment 2 to this letter supersede Tables 1 through 14 provided in Attachment 2 to Reference 1.

A number of assumptions in the analyses were revised to support the LOCA reanalysis. As a result of these changes, it is necessary to revise two of the proposed TS changes identified in Reference 1. The proposed main steam isolation valve leakage has been revised to assume a total leakage of 200 standard cubic feet per hour (scfh) as opposed to the originally proposed total leakage of 250 scfh. In addition, AmerGen has decided to withdraw the proposed changes to TS Section 5.5.7, "Ventilation Filter Testing Program (VFTP)," paragraph c. These changes would have revised the allowed methyl iodide penetration value for the laboratory testing of the ESF ventilation systems filters. The revised markups reflecting the change to the total MSIV leakage is provided in Attachment

3. The retyped TS page is provided in Attachment 4. The markup of the associated Bases page is provided in Attachment 5 for information only. These pages will supersede the pages provided in Reference 1.

There are no regulatory commitments contained in this letter.

AmerGen has reviewed the information supporting a finding of no significant hazards consideration that was previously provided to the NRC in Reference 1. The supplemental information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration.

August 19, 2005

-.U. S. -Nuciear-Regulatory-Commission Page 3 If you have any questions concerning this letter, please contact Mr. Timothy A. Byam at (630) 657-2804.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 19t day of August 2005. -

Resp. ctfully, Keith R. Jury Director - Licensing and Regulatory Affairs Attachments:

1. Response to Request for Additional Information

2. Clinton Power Station (CPS) Plant Parameters Tables

3. Markup of Proposed Technical Specifications Page

4. Retyped Technical Specifications Page

5. Markup of Proposed Technical Specification Bases Page

Enclosure:

CD-ROM Containing Calculation C-020, Revision 3 and Calculation C-023, Revision 1 cc: Regional Administrator - NRC Region IlIl NRC Senior Resident Inspector - Clinton Power Station Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT 1

.--------- Response to-Request for Additional Information NRC Request I Clinton's use of the main steam line aerosol deposition methodology from AEB-98-03, "Assessment of Radiological Consequences for the Perry Pilot Plant Application Using the Revised (NUREG-1465) Source Term," appears to be non-conservative. Please address the following concerns:

a. AEB-98-03 modeling assumed 2 removal nodes in each of the unbroken steam lines, with each segment well-mixed. The broken steam line was modeled as one segment (removal node). Clinton extrapolates use of the AEB-98-03 methodology by modeling main steam line deposition in 3 nodes, using the same 50t percentile deposition rate value (deposition velocity) in each node. The staff thinks that this use overestimates the deposition in the later nodes. The model currently used by Clinton assumes the same rate of deposition in each node which is ultimately based on a particle size distribution that has not undergone any change through deposition in upstream nodes. In other words, the removal of the larger, more quickly and easily deposited aerosols would change the size distribution of aerosols in the piping in later piping segments. These later piping segments would be expected to have a higher concentration of smaller aerosols that would be less likely to be deposited, and the deposition velocity in these segments (modeled as removal nodes) should be reduced to reflect this change. Please discuss whether your aerosol deposition model accounts for or otherwise addresses this change in the aerosol size distribution due to deposition in upstream piping.

b. The calculated aerosol removal rate increases over time (as indicated in the licensee's spreadsheet calculation of equivalent aerosol filter efficiency in Appendix A of the March 30, 2005 submittal), where the staff would expect the removal rate to decrease over time because most of the easily deposited aerosols have already been deposited in previous time periods. Please discuss whether your aerosol deposition model accounts for or otherwise addresses this change in the aerosol size distribution over time due to deposition.

c. Half of the pipe circumference was multiplied by the pipe segment length to estimate the aerosol settling area. This formulation appears to include essentially vertical sections of pipe in the settling area, and thus may be non-conservative. Please discuss the effect of including vertical sections, if any, in the estimated aerosol settling area and the resultant effect on aerosol removal.

Response to Request I 1.a The aerosol deposition model now accounts for or otherwise addresses the change in the aerosol size distribution due to deposition in upstream piping. The detailed description of the aerosol deposition treatment can be found in calculation C-020 Revision 3, section 5.4.6.

1.b AmerGen believes that the conservatisms in the LOCA calculation bound the effects of changes in the deposition rate during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. However, AmerGen has reevaluated the assumption of aerosol deposition and has decided to no longer take any Page 1

ATTACHMENT I

-- Response to Request-for-Additional-Information credit for deposition after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Calculation C-020 Revision 3, section 5.4.6 includes further details on the aerosol size distribution over time due to deposition.

1.c AmerGen has revised the LOCA analysis such that the conservative approach of the projected areabof the horizontal pipe (iLe-. Uength-x Diameter) is now used as the settling area as discussed in calculation C-020 Revision 3, section 5.4.6.

NRC Request 2 Please address these further considerations with respect to the modeling of main steam line deposition:

a. What is the effect of the decay heat from deposited material in the main steam piping with respect to iodine re-evolution?

b. The report on which the elemental iodine deposition rate was based ("MSIV Leakage Iodine Transport Analysis," J.E. Cline, August 20, 1990) also includes resuspension and conversion. Have you considered the effect of resuspension and conversion on the elemental iodine deposition rate?

c. Does the pipe wall temperature used in elemental iodine deposition modeling account for the decay heat of the deposited material in the pipe? How would this additional source of heat affect the deposition assumed?

Response to Request 2 2.a The effect of the decay heat from deposited material in the main steam piping with respect to iodine re-evolution has been evaluated. The decay heat added to the piping is calculated to be less than 80 watts and has no significant effect on re-evolution. The description of this evaluation can be found in calculation C-020 Revision 3, Attachment H.

2.b The effect of resuspension of elemental iodine and the associated conversion to organic iodine is now considered. The description of this treatment can be found in calculation C-020, Revision 3 in Section 5.4.6.2.

2.c The effect of the decay heat from deposited material in the main steam piping with respect to iodine deposition has been evaluated. The decay heat added to the piping is calculated to be less than 80 watts and has no significant effect on deposition or pipe wall temperature. The description of this treatment can be found in calculation C-020, Revision 3 in Attachment H.

NRC Request 3 By licensee letter (RS-03-239), dated December 23, 2003, in response to NRC staff's Question 9, it was stated that the LOCA analysis would no longer credit a 50 percent reduction Page 2

ATTACHMENT I Response to Request for Additional Information in the feedwater isolation valve (FWIV) leak rate after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The correction would be noted in Table 4, "Key LOCA Analysis Inputs and Assumptions" when a revised analysis would be subsequently submitted. The revised analysis was submitted by licensee letter (RS-05-033),

dated March 30, 2005. In revised Table 4, the 50 percent reduction in FWIV leak rate after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> does not appear to have changed. Is this assumption used in the revised LOCA analysis?

Response to Request 3 The LOCA analysis was previously revised as indicated. However, due to an oversight the notation in Table 4 regarding the 50% reduction in FWIV leak rate after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was not changed. The correct value for this parameter is reflected in the parameter table provided in . These parameter tables supersede Tables 1 through 14 provided in Attachment 2 to the original amendment request (Reference 1).

NRC Request 4 The staff understands how the new filter penetrations requested in the submittal were developed. However, the staff requests that the licensee provide technical data and information to show that the filter, if they were tested and used in the degraded state, would provide satisfactory performance for the entire surveillance period and be sufficiently capable of mitigating an event if it were needed. The staff has reasonable assurance that filters tested in accordance with the criteria set forth in Regulatory Guide (RG) 1.52 Revision 2 or Revision 3, which incorporated a safety factor of 2 or greater, would provide adequate performance to protect public health and safety. A number of studies and data have been developed which confirm adequate performance at the conditions specified in the RG. For penetrations that exceed the values listed in the RG, the staff has no data upon which to base degraded filter performance and thus requires this information to assess the impact on safety.

Response to Request 4 AmerGen has reevaluated the proposed changes to the filter penetrations and has decided to withdraw the request to revise these values. Therefore, AmerGen will continue to evaluate CPS filter performance against the currently existing filter penetration values specified in TS Section 5.5.7, "Ventilation Filter Testing Program (VFTP)," paragraph c.

References

1. Letter from Michael J. Pacilio (AmerGen Energy Company, LLC) to U. S. NRC, "Request for License Amendment Related to Application of Alternative Source Term," dated April 3, 2003 Page 3

ATTACHMENT 2 Clinton Power Station (CPS) Plant Parameters Tables

Clinton AST Parameters Page I of 27 8/18/2005 Clinton Power Station (CPS) Plant Parameters Tables (Includes Changes Made Since April 3, 2003 Submittal)

Table 1: Clinton General Parameters and Methods Applicable to Design Basis Accidents Page 2 Table 2: Clinton Parameters and Methods Applicable to LOCA Page 6 Table 3: Clinton Parameters and Methods Applicable to Suppression Pool pH Transient Analysis Page 11 Table 4: Clinton Parameters and Methods Applicable to CRDA Page 13 Table 5: Clinton Parameters and Methods Applicable to the Main Steam Line Break (MSLB) Accident Page 15 Table 6: Clinton AEB 98-03 Parameters and Methods Used for MSIV Leakage Analysis Page 16 Table 7: Clinton Parameters for FWIV Piping Deposition Page 20 Table 8: Clinton Parameters for Purge Piping Deposition Page 22 Table 9: Clinton Tech Spec Changes Since 04/03/03 Submittal (Affected Pages) Page 24 Table 10: Summary of Clinton LOCA Dose Re-Analysis Page 26 Table 11: Summary of Clinton MSLB Dose Re-Analysis Page 27 Table 12: Summary of Clinton CRDA Dose Analysis (Unchanged by this Supplement) Page 27

Clinton AST Parameters Page 2 of 27 8/18/2005 Table 1: Clinton General Parameters and Methods Applicable to Design Basis Accidents General ValntyLiese ubmteo ehdInFinal Supplemehted Value or AST Analysis Currentl censed Submitted in Method Used in l Justification for Change Parameter or Method Value or Method April 3, 2003 CretATAayi

____ ___ ____ ____ ____ ____A ST Application Cr e t A T A ayi Core Power Level 3543 MWth (current) 3543 MWth (current) 3543 MWth (current) No changes 100% power is 3473 MWth, 100% power is 3473 MWth, 100% power is 3473 MWth, 102% power with RG 1.49 102% power with RG 1.49 102% power with RG 1.49 instrument uncertainty instrument uncertainty instrument uncertainty allowance is 3543 MWth. allowance is 3543 MWth. allowance is 3543 MWth.

Core Source Terms TID-14844 ORIGEN2-based inventory ORIGEN2-based inventory Changed from currently licensed for Includes the 60 isotopes In Includes the 60 isotopes in the AST the standard RADTRAD standard RADTRAD library library No change since 04/03/03 submittal.

TID-14844 continues to be used for Equipment Qualification purposes.

Dose Conversion Factors for Thyroid - ICRP 30 Federal Guidance Reports Federal Guidance Reports 11 & Changed from currently licensed for Thyroid Inhalation, Whole Body, Whole Body- RG 1.109 11 & 12 12 AST and TEDE Dose TEDE - N/A (RADTRAD Input file) (RADTRAD input file)

(TEDE only) (TEDE only) No change since 04/03/03 submittal Personnel Dose Inputs No Changes Onsite Breathing Rate 3.47E-04 m3 /sec 3.47E-04 m3 /sec 3.47E-04 m3/sec Offsite Breathing Rate 0 - 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />s: 3.47E-04 m3 /sec 3.47E-04 m3 /sec 3.47E-04 m3/sec 8 - 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s: 1.75E-04 m3 /sec 1.75E-04 m3 /sec 1.75E-04 m3/sec 1 - 30 days: 2.32E-04 m3 /sec 2.32E-04 m3 /sec 2.32E-04 m3 /sec CR Occupancy Factors 0- 1 day: 1.0 1.0 1.0 1 - 4 days: 0.6 0.6 0.6 4 - 30 days: 0.4 0.4 0.4 Distance to EAB 975 meters 975 meters 975 meters No Changes EAB Dispersion Factors N/A - New X/Qs needed for Changed from currently licensed for 0 - 2 hr AST 2.46E-04 (sec/m 3 ) 2.46E-04 (sec/i 3) AST (PAVAN used)

No change since 04/03/03 submittal

Clinton AST Parameters Page 3 of 27 8/18/2005 Table 1: Clinton General Parameters and Methods Applicable to Design Basis Accidents General or Method Value Final Supplemented Value or AST Analysis Currently Licensed Submitted inMehdUdInJsicaonfrC ng Parameter or Method Value or Method April 3, 2003 Murentho USedAnaJstfiatosfrihag

___________________ AST Application CretATAayi Distance to LPZ 4018 meters 4018 meters 4018 meters No Changes LPZ Dispersion Factors N/A - New X/Qs needed for Changed from currently licensed for AST (sec/r 3 ) (sec/m 3 ) AST (PAVAN used) 0 - 8 hr 2.48E-05 2.48E-05 8 - 24 hr 1.65E-05 1.65E-05 No change since 04/03/03 submittal 1 - 4 day 6.81 E-06 6.81 E-06 4 - 30 day 1.91 E-06 1.91 E-06 CR Filtered Intake: N/A - New XIQs needed for Changed from currently licensed for Dispersion Factors AST (sec/r 3 ) (sec/i 3 ) AST (ARCON96 used) 0 - 2 hr 2.36E-04 2.36E-04 2 - 8 hr 1.77E-04 1.77E-04 No change since 04/03/03 submittal 8 - 24 hr 7.33E-05 7.33E-05 1 -4 day 5.33E-05 5.33E-05 4 - 30 day 4.48E-05 4.48E-05 CR Unfiltered Intake: New X/Qs calculated for Changed from currently licensed for Dispersion Factors AST (sec/m 3 ) (sec/m 3 ) AST (ARCON96 used) 0 - 2 hr 1.54E-03 1.54E-03 2 - 8 hr 1.09E-03 1.09E-03 No changes since 04/03/03 8 - 24 hr 4.67E-04 4.67E-04 submittal 1 -4 day 3.21 E-04 3.21 E-04 4 - 30 day 2.64E-04 2.64E-04 Filtered Intake Rate - Hi-Rad 3,000 cfm + 10% - 3300 cfim 3,000 cfm + 10% = 3300 cfm 3,000 cfm - 10% = 2700 cfm Supported by design basis analysis Mode Sensitivity analysis Indicates the -10% uncertainty Is bounding CR Filtered in-leakage 650 cfm 650 cfm 650 cfm No Change to TS 3.7.3.5 Control Room Filtered and N/A - New for AST Allowed Unfiltered Conservative Unfiltered Supplement dated March 30, 2005 Unfiltered Inleakage Control Inleakage [cfm] = Inleakage Allowance (cfm) (question #12), and further Margin Exchange Basis 786.4 - 0.2868 * (measured = (IDF - ITS.)

• 0.32 supplemented by this table.

Filtered Inleakage) and with 5% Instrument where: The 0.32 value corresponds to the Uncertainty IDF = Analyzed filtered penetration associated with the Inleakage (1100 cfm) accident analysis assumption of a Allowed Unfiltered ITS. = Technical Specification 70% charcoal adsorber efficiency

Clinton AST Parameters Page 4 of 27 8/18/2005 Table 1: Clinton General Parameters and Methods Applicable to Design Basis Accidents Genera!urnlyLcne Vaubmteo ehdInFinal Supplemented Value or AST Analysis CValue or Method Suibmitd in0 Method Used In Justification for Change Parameter or Method ValueeonMethoTApril3,y200

__________________________AST Application CretATAayi Inleakage [cfm] = 1 3.7.3.5 limit of 650 cfm or less for the control room recirculation 747 - 0.273 * (measured based on measured filtered filter, combined with the TS 5.5.7.b Filtered Inleakage) inleakage. in-place testing penetration allowance of 2%.

Independent RADTRAD analyses have shown that this relationship is conservative over the range of applicability.

The design basis accident analyses are run with the assumption of a filtered inleakage of 1100 cfm and no unfiltered inleakage. Filtered inleakage is now controlled to less than 650 cfm (which includes instrument uncertainty).

The most recent tracer gas test showed filtered inleakage well within the TS 3.7.3.5 limit and there was no apparent unfiltered inleakage.

Unfiltered Intake Rate - Hi-Rad 10 cfm 600 cfm 144 cfm with maximum Includes 10 cfm for ingress/egress.

Mode allowable filtered Inleakage of Equivalency formula provided in 650 cfm. March 30, 2005 supplement and as See Margin Exchange modified in this supplement as Formulation above supported by design basis analysis.

CR Intake Filter Efficiency 99% for all lodines 97% for all lodines 99% for all lodines Changed back to currently licensed value. Based on this change, proposed revision to TS 5.5.7c has been withdrawn.

CR Filtered Recirc Rate 61,000 cfm - 10% = 54,900 61,000 cfm - 10% = 54,900 61,000 cfm - 10% = 54,900 cfm No Changes cfm cfm CR Recirc Filter Efficiency 70% for all lodines (currently 70% for all lodines (currently 68% for all lodines (reduced Accounts for 2% filter bypass licensed value) licensed value) by 2% for bypass) (TS 5.5.7)

Clinton AST Parameters Page 5 of 27 8/18/2005 Table 1: Clinton General Parameters and Methods Applicable to Design Basis Accidents General Value or Method Final Supplemented Value or AST Analysis Currently Licensed Submitted in Method Used in Justification for Change Parameter or Method Value or Method April 3, 2003 Current AST Analysis

__________________________ ~~~AST A pplication__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Control Room Volume 324,000 cu. ft. (includes 324,000 cu. ft. (includes 324,000 cu. ft. (includes TSC) No Changes TSC) TSC) (TSC volume included for conservatism)

Control Room Filtered Intake 20 minutes 20 minutes 20 minutes Added 10% for uncertainty.

and Recirculation Air Filtration During this period of no During this period of no During this period of no filtration The outside air intake isolation will Initiation Time filtration and no CR filtration and no CR and no CR pressurization, an occur automatically at time T = 0, (manual) pressurization, an inleakage pressurization, an inleakage of 1650 cfm is with LOOP and/or single failure.

of 1500 cfm is assumed, inleakage of 1650 cfm Is assumed, which is 1/2 of This is assured by dual isolation which is 1/2 of assumed assumed, which is 1/2 of assumed filter makeup value dampers in series (to account for filter makeup value required assumed filter makeup used for CR pressurization. single failure), which fail close on for CR pressurization. value used for CR loss of power and hi-rad signal.

pressurization. In case of a single failure of one of the emergency power sources, it is possible that manual action would be required to start one of the HVAC trains in emergency mode (i.e., the control room envelope could be unpressurized, with 0 cfm outside air intake for the first 20 minutes).

1650 cfm is used for unfiltered inleakage that might occur during the possible unpressurized condition with none of the HVAC trains operating for the first 20 minutes.

Clinton AST Parameters Page 6 of 27 8/18/2005 Table 2: Clinton Parameters and Methods Applicable to LOCA LOCA Value or Method Submitted ASTAnayi Currently Licensed InFinal Supplemented Value or AST Analysis o dApril 3, 2003 Method Used in Justification for Change Parameter or Method oAST Aplication Current AST Analysis Primary Containment Mixing Instantaneous mixing in The analysis supporting The analysis supporting the RG 1.183 combined drywell and the submittal used a submittal used a drywell bypass wetwell volume drywell bypass leakage leakage rate of 3,000 cfm for No Changes since 04/03/03 rate of 3,000 cfm for the the first two hours, followed by submittal first two hours, followed by an assumption of well-mixed an assumption of well- drywell-containment conditions mixed drywell containment thereafter.

conditions thereafter.

Primary Containment Leak Rate: Leak Rate: Leak Rate:

Leakage to Secondary 0.92*L, = 0.598%/o/day from 0.92*La = 0.598%/day from 0 0.92*L, = 0.598%/day from 0 to No Change during drawdown Containment 0 to 188 seconds (Unfiltered to 10 min (Unfiltered during 10 min (Unfiltered during period. However, drawdown period during drawdown period) drawdown period) drawdown period) changed from 188 seconds to 10 minutes as supported by analysis.

0.92*La = 0.598%/o/day from 0.92*L, = 0.598 0/o/day from 0.92*La = 0.598%/o/day from 10 No Change (10 min to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) 188 seconds to 30 days 10 min to 24 hrs (SGTS min to 24 hrs (SGTS filtered)

(SGTS filtered) filtered)

= 0.2990/o/day from = 0.380 0/o/day from 1 Reduction to 50% permitted by RG 1 to 30 days (SGTS filtered) to 30 days (SGTS filtered) 1.183 after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if justified by analysis. Further changes required (reduced to 63.6%) after re-evaluation per this supplement.

ECCS Leakage into Secondary Containment Leak Rate No ECCS Leakage 5 gpm (2 times the 5 gpm (2 times the maximum Design basis analysis maximum allowable admin allowable admin limit) limit)

Fraction Flashed N/A 1.36% 10% RG 1.183, Design basis analysis Filtered by SGTS N/A Yes - after drawdown Yes - after drawdown No Change since 04/03/03

Clinton AST Parameters Page 7 of 27 8/18/2005 Table 2: Clinton Parameters and Methods Applicable to LOCA LOCA Liesd Vleo ehdSbitd Final Supplemented Value or AST Analysis Currently in incensed Method Used in Justification for Change Parameter or Method Value or Method April 3, 2003 CretATAayi AST Application CretATAayi submittal Purge Penetrations 101 and Leak Rate (for each of two Leak Rate (for each of two Leak Rate (for each of two 102 Leakage to the penetrations): penetrations): penetrations):

Environment 0.01*La = 0.0065%/o/day 0.02*L, = 0.013 0/lday from 0.02*La = 0.013%/day from 0 to Design basis analysis per 04/03/03 from 0 to 30 days 0 to 1 day I day submittal (Included as part of the 0.08*La value) = 0.0065 0/o/day = 0.008270/o/day from Reduction by a 0.636 factor based from 1 to 30 days 1 to 30 days on square root of ratio of containment post-LOCA pressure at 1 day to 9 psig test pressure.

This leakage to be counted against the total La, but not part of 0.08*L, limit.

Primary Containment Leak 0.65% per day 0.65% per day for first 24 0.65% per day for first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> No Change (0-24 hours)

Rate (SGTS Filtered and hours (La); (La);

Secondary Containment Bypass) 0.325% per day thereafter 0.413% per day thereafter Changed for AST to 50% after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per the 04/03/03 submittal.

Re-evaluation determined reduction by a 0.636 factor based on square root of ratio of containment post-LOCA pressure at 1 day to 9 psig test pressure.

Total MSIV Leak Rate Limits 112 scfh total in four lines 250 scfh total for four lines 200 scfh total for four lines Supported by design basis analysis 100 scfh for any one line 100 scfh for any one line calculation C-020 Post-24 hours analytical 125 scfh total 127 scfh total, 63.6 scfh for Changed for AST to 50% after 24 values any one line hours per the 04/03/03 submittal.

Re-evaluation determined reduction by a 0.636 factor based on square root of ratio of containment post-LOCA pressure at 1 day to 9 psig test pressure.

Clinton AST Parameters Page 8 of 27 8/18/2005 Table 2: Clinton Parameters and Methods Applicable to LOCA LOCA Value or Method Submilled Final Supplemented Value or AST Analysis Currently Licensed InMehdUdInJsicaonfrCng Parameter or Method Value or Method April 3, 2003 MeCutoe Ued in Justification for Change

_______________________ AST Application CretATAayi FWIV leak rate: Each of two penetrations Each of Two Penetrations Total for two penetrations Changed per Supplement dated December 23, 2003 Question #1 Air (Containment 17.2 cfm from t = 0 to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 10.98 cfm from 21.15 10.98 cfm for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (before (Page 6 of 11) atmosphere): minutes to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> FWIV LCS fills the lines)

Water (ECCS): 3 gpm from t = 0 to 30 days 2 gpm from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 24 2 gpm (constant) from 0 to 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, 1 gpm after 24 days hours Flashing Fraction: 1.36% 1.36% 10%

Primary Containment 8.0% La for duration of 8.0% L, for first day 8.0% L, for first day No Change since 04/03/03 Bypassing Secondary accident submittal Containment 4.0% La after first day 5.09% L, after first day Reduction by a 0.636 factor based on square root of ratio of containment post-LOCA pressure at 1 day to 9 psig test pressure.

Aerosol Natural Deposition 50% instantaneous plateout Credit Is taken for natural Credit is taken for natural No change since 04/03/03 Coefficients Used in the (RG 1.3) deposition of aerosols deposition of aerosols based on submittal.

Containment based on equations for the equations for the Power's Power's model In model in NUREG/CR 6189 and NUREG/CR 6189 and built built into RADTRAD as natural Into RADTRAD as natural deposition time dependent deposition time dependent lambdas.

lambdas.

No credit is assumed for natural No credit Is assumed for deposition of elemental or natural deposition of organic iodine elemental or organic Iodine Suppression pool scrubbing Factor of 10 for elemental Not credited Not credited No change since 04/03/03 and particulate submittal.

Deposition/Plate-out (where None Calculated for horizontal AEB 98-03 well-mixed flow is Supplement dated March 30, 2005 credited) segments only using now assumed Instead of plug and as modified in this supplement.

RADTRAD Brockmann- flow. Refer to design analysis for details Blxler model. (see attached Tables 6, 7, and 8

Clinton AST Parameters Page 9of27 8/18/2005 Table 2: Clinton Parameters and Methods Applicable to LOCA Param CAer eMeo l VleoMtd ]/Value or Method Submitted Final Supplemented Value r ASTAnayi Currently Licensed InFiaSupe ntdVleo Parameter or Method Value or Method April 3, 2003 Murentho USed AayinsutfctonfrCag AST Application CretATAayi Aerosol settling In Aerosol settling In horizontal for AEB 98-03 Parameters for horizontal lines only; lines only; elemental MSIV, FWIV, Purge lines, elemental deposition In all deposition In all credited respectively).

credited lines. lines.

Main Steam Line and Two-hour holdup in main No credit Is taken for No credit is taken for holdup No change since 04/03/03 Condenser Holdup Credit for steam line. 100% of MSIV holdup and plate-out and plate-out downstream of submittal.

MSIV Leakage leakage filtered by SGTS. downstream of seismically seismically qualified main qualified main steam steam piping or in the piping or in the condenser condenser since these since these components components have not been have not been evaluated evaluated for seismic for seismic ruggedness. ruggedness.

Releases to Containment Instantaneous release No Core Activity Release No Core Activity Release for No change since 04/03/03 for first 2 minutes. Release first 2 minutes. Release submittal.

Fractions and Timing per Fractions and Timing per RG RG 1.183 1.183 SGTS flow rate 4000 cfm + 10% = 4400 cfm 4000 cfm + 10% = 4400 cfm 4000 cfm + 10% = 4400 cfm No Change Containment Mixing Not credited Not credited Not credited No Change Natural Deposition in 50% instantaneous plateout Powers' algorithm built Powers' Algorithm built into No change since 04/03/03 Containment (RG 1.3) Into RADTRAD RADTRAD submittal.

Containment Spray Removal Not credited Not credited Not credited No Change Mechanism Containment Volumes Drywell 241,699 cu. ft. 241,699 cu. ft. 241,699 cu. ft. No Change Containment 1,512,341 cu. ft. 1,512,341 cu. ft. 1,512,341 cu. ft. No Change Primary Containment 1.754E+06 cu. ft. 1.754E+06 cu. ft. 1.754E+06 cu. ft. No Change Total (where applicable) _

Minimum Suppression Pool 146,400 ft3 146,400 ft 146,400 ft No Change volume LOCA Break Location Recirc suction line (largest Recirc suction line (largest A main steam line is now Supplement dated March 30, 2005 Assumed pipe causes the quickest pipe causes the quickest loss assumed to break just before Response to Question #1, Paqe 8

Clinton AST Parameters Page 10 of 27 8/18/2005 Table 2: Clinton Parameters and Methods Applicable to LOCA LOCA Value or Method Submitted Final Supplemented Value or AST Analysis Currently Licensed InMehdUdInJsicaonfrCng Parameter or Method Value or Method April3et In Use in Justification for Change loss of reactor coolant) of reactor coolant) the Inboard MSIV to minimize of 11 deposition credit.

MSIV Leakage Rate 112 scfh total for all four 100 scfh for two shortest 100 scfh for two shortest Design analysis Distribution steam lines lines and 50 scfh for the lines totaling 200 scfh total third, totaling 250 scfh total allowable leakage allowable leakage Fraction of Containment 100% for first 188 seconds, 100% for first 10 minutes, 100% for first 10 minutes, No change since 04/03/03 Leakage that Bypasses 8% for 188 seconds to 30 8% 10 minutes to 30 days 8% 10 minutes to 30 days submittal.

SGTS days Secondary Containment 188 seconds 10 minutes 10 minutes Supported by design basis analysis Drawdown Time (+ 2 minutes during gap (+ 2 minutes during gap release release phase) phase)

SGTS Iodine Efficiency 99% 97% 99% Changed back to currently licensed value. Based on this change, proposed revision to TS 5.5.7c has been withdrawn.

Clinton AST Parameters Page IIof 27 8/18/2005 Table 3: Clinton Parameters and Methods Applicable to Suppression Pool pH Transient Analysis Suppression Pool pH Currently Licensed Vaubmteo ehdInFinal Supplemented Value or Transient AST Analysis Value or Method 3 uAbittd ion Method Used In Justification for Change Parameter__or__Method_ AST Application Current AST Analysis Hydriodic acid addition N/A - Not required for TID- 5% of core iodine 5% of core iodine inventory, No change since 04/03/03 14844 Inventory, released at a released at a constant rate over submittal.

constant rate over the the release accident release accident Nitric Acid production from N/A - Not required for TID- As per Grand Gulf 12/22100 As per Grand Gulf 12/22/00 No change since 04/03/03 irradiation of water and air 14844 letter to NRC letter to NRC submittal.

during accident Hydrochloric Acid addition by N/A - Not required for TID- As per Grand Gulf 12/22100 As per Grand Gulf 12/22/00 No change since 04/03/03 radiolysis of exposed 14844 letter to NRC, with AST- letter to NRC, with AST-based submittal.

chloride-bearing materials based containment post- containment post-LOCA inside containment during LOCA activities activities accident (addition by pyrolysis will not be considered as temperatures near 572 F are required)

Cesium Hydroxide addition N/A - Not required for TID- 5% of core cesium 5% of core cesium inventory, No change since 04/03/03 from release of cesium 14844 Inventory, released at a released at a constant rate over submittal.

constant rate over the the release accident release accident SBLCS credit N/A - Not required for TID- Credited for pH control Credited for pH control Full Design analysis 14844 Full sodium pentaborate sodium pentaborate injection injection into suppression into suppression pool within No change since 04/03/03 submittal pool within several hours several hours of accident of accident Initiation and initiation and pool is well mixed pool is well mixed Minimum weight of sodium N/A - Not required for TID- Limiting value = 4246 lb. Limiting value = 4246 lb. for No change since 04/03/03 pentaborate in Liquid Control 14844 for both current and both current and extended submittal.

Tank extended power uprate power uprate conditions (with conditions (with enrichment to 30 atom % B'0 ).

enrichment to 30 atom % Corresponding molecular B'°). Corresponding weights of Na2B1 0016 10H 2 0 molecular weights of are 590.30 g/mole with natural Na2B 1 0016 10H 2 0 are boron (19.78 atom % B'0) and

Clinton AST Parameters Page 12 of 27 8/18/2005 Table 3: Clinton Parameters and Methods Applicable to Suppression Pool pH Transient Analysis Suppression Pool pH ValntyLiese ubmteo ehdInFinal Supplemented Value or Transient AST Analysis Cue L n Method Used In Justification for Change Parameter or Method VleoMehdArl3203Current ~~~AST A pplication__ AST Analysis 590.30 g/mole with natural 589.28 g/mole with 30% B1 u boron (19.78 atom % 610) enrichment.

and 589.28 glmole with 30% 1° enrichment. .

Iodine Re-evolution from N/A - Not required for TID- None. Suppression pool None. Suppression pool pH Supported by design analysis Containment Liquids (none if 14844 pH stays at 7 or above stays at 7 or above during pH maintained above 7) during entire accident. entire accident. No change since 04/03/03 submittal

Clinton AST Parameters Page 13 of 27 8/18/2005 Table 4: Clinton Parameters and Methods Applicable to CRDA CRDA Value or Method Final Supplemented Value or AST Analysis Currently Licensed Submitted in Method Used In Justification for Change PrmtroMehdValue or Method April 3, 2003 AST Application CretATAayi Damaged Fuel Releases to 1200fuel rods failed - (GE 1200fuel rods failed - (GE 1200fuel rods failed - (GE No Change Reactor Coolant 10x10 fuel) 10x10 fuel) 1Ox1O fuel)

Fraction of failed fuel that 1% (Conservative rounding 1% (Conservative rounding 1% (Conservative rounding of No Change melts* of value used in NEDE- of value used in NEDE- value used in NEDE-31152P, 31152P, Rev. 7) 31152P, Rev. 7) Rev. 7)

Fuel Bundles in Core 624 624 624 No Change Fuel peaking factor 1.7 1.7 1.7 No Change Radioactivity transport Carryover with steam to Carryover with steam to Carryover with steam to No Change pathway condenser prior to MSIV condenser prior to MSIV condenser prior to MSIV closure and leakage from closure and leakage from closure and leakage from condenser to the condenser to the condenser to the environment environment environment Fuel released activity carried Noble Gases 100% Noble Gases 100% Noble Gases 100% No Change to condenser before MSIV lodines 10% lodines 10% lodines 10%

complete closure Remaining radionuclides Remaining radionuclides Remaining radionuclides 1%

1% 1%

Activity in condenser release Noble Gases 100% Noble Gases 100% Noble Gases 100% No Change to environment lodines 10% lodines 10% lodines 10%

Remaining radionuclides Remaining radionuclides Remaining radionuclides 1%,

1%, with released Iodine 1%, with released Iodine with released Iodine species as species as follows: species as follows: follows:

97% elemental and 97% elemental and 97% elemental and 3% organic 3% organic 3% organic Airborne condenser activity 1% per day for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 1% per day for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 1% per day for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, then 0 No Change leakrate to environment then 0 (or at the most then 0 (or at the most (or at the most limiting flow rate limiting flow rate of turbine or limiting flow rate of turbine or of turbine or condenser flow condenser flow paths such condenser flow paths such paths such as unisolated as unisolated mechanical as unisolated mechanical mechanical vacuum pumps, vacuum pumps, with credit vacuum pumps, with credit with credit for available filters,

Clinton AST Parameters Page 14 of 27 8/18/2005 Table 4: Clinton Parameters and Methods Applicable to CRDA CRDA VleoMehdFinal Supplemented Value or AST Analysis cauet Lioensed Subit in Method Used In Justification for Change Parameter or Method ValueeonMethoTApril3,y200

__ __ ____ _____ ____ ____A ST Application C r e t A T A ay i for available filters, or for available filters, or or unprocessed air ejectors).

unprocessed air ejectors). unprocessed air ejectors).

Credit for activity decay Yes Yes Yes No Change during condenser residence Credit for activity decay after No No No No Change release to environment Credit for accident Yes, isolation of Mechanical Yes, isolation of Mechanical Yes, isolation of Mechanical No Change termination features Vacuum Pumps on MSLRM Vacuum Pumps on MSLRM Vacuum Pumps on MSLRM high-high rad signal. high-high rad signal. high-high rad signal.

Credit for Holdup in Turbine No No No No Change Building Condenser Volume 175,000 cu. ft. 175,000 cu. ft. 175,000 cu. ft. No Change

Clinton AST Parameters Page 15 of 27 8/1 8/2005 Table 5: Clinton Parameters and Methods Applicable to the Main Steam Line Break (MSLB) Accident MSLB VleoMehdFinal Supplemented Value or AST Analysis Currently Licensed Submitted In Method Used In Justification for Change Parameter or Method Value or Method April 3, 2003 Parameter__or__Method_ AST Application Current AST Analysis Discharged Mass 96,250 lb (53,750 lb liquid 96,250 lb (53,750 lb liquid 140,000 lb liquid (no steam) This change ensures that the and 42,500 lb steam) and 42,500 lb steam) (40% flashing) discharged mass is maximized (conservative application of SRP 15.6.4, Paragraph 111.2.a).

The value of 140,000 lb liquid is only used for control room and offsite dose analysis. The values for coolant released listed in the current license basis remain the basis for no fuel damage.

MSIV closure time 5.5 seconds 5.5 seconds 5.5 seconds No Change Analyzed Cases and Activity Two cases analyzed, one Two cases analyzed, one Two cases analyzed, one NRC RAI question directed at Releases without and one with without and one with without and one with Dresden & Quad Cities received postulated iodine spike, postulated iodine spike, postulated Iodine spike, June 29, 2005 required the addition using TS reactor coolant using TS reactor coolant using TS reactor coolant of cesium activity to be considered activity limits and reactor activity limits and reactor activity limits and reactor in the dose consequence analysis.

coolant iodine and noble gas coolant iodine and noble gas coolant Iodine and noble gas activity concentrations. activity concentrations. activity concentrations.

Cesium activity is now considered in addition to Iodine and noble gas.

Dispersion Factors for MSLB Supported by design basis analysis Control Room: Not calculated N/A - Hemispherical cloud N/A - Hemispherical cloud No change since 04/03/03 submittal model model EAB: 1.8E-04 3.68E-04 3.68E-04 RG 1.5 LPZ: 4.2E-05 1.02E-04 1.02E-04 RG 1.5

Clinton AST Parameters Page 16 of 27 8/18/2005 Table 6: Clinton AEB 98-03 Parameters and Methods Used for MSIV Leakage Analysis AEB 98-03 Parameters Final Supplemented Value or Method and Methods Used for Used in Justification MSIV Leakage Analysis Current AST Analysis Leakage Distribution 50% in MS Line A (Shortest Unbroken Leakage limits are 200 scfh Total, and 100 scfh for any one line. Maximizing flow through line) shorter lines minimizes piping deposition credit. Lines selected for minimization of effective 50% in MS Line B (Shortest line when filter efficiencies.

inboard piping assumed broken and unavailable)

Nodalization for AEB Two-node treatment is used for each Outboard MSIV failure is selected since this maximizes the volume of piping in which the 03; Single Active Failure steam line in which flow occurs. The fluid is depressurized. This in turn minimizes deposition and this treatment is used for all Assumptions first node is from the reactor vessel to steam lines.

the inboard MSIV. The second node is from the inboard MSIV to the Auxiliary Although the CPS design basis line break associated with the non-mechanistic R.G. 1.183 Building / Turbine Building wall. Steam source terms is a recirc line break, a steam line break is assumed in order to ensure line piping is seismically supported conservative treatment of deposition. That is assumed to result in the unavailability for through this wall with consideration of deposition of inboard piping on the broken steam line. The inboard node for the broken SSE loads. This serves to protect the steam line is not credited.

secondary containment gas control boundary. For conservatism and for consistency with AEB-98-03, only two nodes are used in any one The Outboard MSIV is assumed to fail steam line. Therefore, penetration piping and seismically qualified piping downstream of the on both steam lines in which flow is outboard MSIV are treated as a single node.

assumed.

Well-mixed modeling for The formulations for effective filter For conservatism, a well-mixed model is used for both inboard and outboard piping nodes.

aerosol gravitational efficiencies in piping segments that are The AEB-98-03 Appendix A formulas are for a well-mixed treatment of a piping segment or settling and elemental used in the CPS AST application are node and are presented for use with gravitational settling of aerosols. This formulation iodine deposition. from AEB-98-03, Appendix A "Use of would also be applicable for elemental iodine removal when the appropriate deposition Plug-Flow and Well-Mixed Models for velocities and deposition areas are used.

Fission Product Deposition in the Main Steam Line for the Perry Assessment" Aerosol Settling Velocities Settling Velocities used for gravitational NRC's AEB-98-03, indicates 'The staff believes that, at this time, a well-mixed model is more settling use a 20-group probability appropriate than a plug flow model for settling in the main steam line. However complete distribution based on the AEB-98-03 mixing may not occur along the entire length of the pipe and, in some pipe segments, plug recommended distribution parameters. flow may exist. Given the conservatism associated with using a well-mixed model for the entire length of the pipe and a number of additional conservatisms inherent in the piping depositions analysis, use of a 10ch percentile settling velocity with a well-mixed model is not appropriate. Additional conservatisms include additional deposition by thermophoresis,

Clinton AST Parameters Page 17 of 27 8/18/2005 Table 6: Clinton AEB 98-03 Parameters and Methods Used for MSIV Leakage Analysis AEB 98-03 Parameters Final Supplemented Value or Method and Methods Used for Used in Justification MSIV Leakage Analysis Current AST Analysis diffusiophoresis, and flow irregularities; addition deposition as a result of hygroscopicity and possible plugging of the leaking MSIV by aerosols. Given the conservatism of the well-mixed assumption, we believe it is acceptable then to utilize median values (as compared to more conservative values) for deposition parameters.

CPS is somewhat different than Perry in that piping downstream from the outboard MSIV to the Auxiliary Building / Turbine Building wall is credited. The NRC staff has questioned whether crediting the same settling velocities throughout the piping system, and treatment of the downstream piping as a third node was adequately conservative. In response, CPS:

1. Has combined penetration piping and downstream piping into a single outboard node;

2. Uses a 20 group probability distribution on settling velocities with settling efficiencies determined for each group and a net weighted average efficiency used, a process that is significantly more conservative than use of a median settling velocity;

3. Takes no credit is taken for aerosol settling after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Other phenomena, such as effects of depletion over time of more easily settled particle sizes are considered to be adequately addressed by the above conservatisms and the significant residual conservatism mentioned in the original AEB-98-03 conclusions quoted above.

Elemental Iodine Removal Elemental iodine deposition velocities, Elemental Iodine deposition is analyzed using the well-mixed model of AEB-98-03, Appendix Parameters resuspension rates, and fixation rates A, where settling velocities and deposition velocities are treated as analogous properties.

are taken from RG 1.183, Appendix A, Reference A-9. The impacts of resuspension from deposited elemental iodine have been evaluated where all re-evolved iodine is treated as organic iodine and instantly released. The dose impacts are minimal.

Actual Inboard Piping For Aerosol Settling For Aerosols - only includes horizontal piping. Settling area is projected horizontal surface Volumes and Surface LINE Vol (ft3) Area(ft2 ) area of horizontal piping only.

Areas MS A 86 58.23 MS B 116 78.32 (Line B assumed broken and not credited)

For Elemental Iodine Deposition For Elemental iodine - includes total piping area and volume.

LINE Vol (ft3) Area(ft 2 )

MS A 157 334 MS B 187 397

Clinton AST Parameters Page 18 of 27 8/18/2005 Table 6: Clinton AEB 98-03 Parameters and Methods Used for MSIV Leakage Analysis AEB 98-03 Parameters Final Supplemented Value or Method and Methods Used for Used in Justification MSIV Leakage Analysis Current AST Analysis (Line B assumed broken and not credited)

Outboard Piping Volumes For Aerosol Settling For Aerosols - only includes horizontal piping. Settling area is projected horizontal surface and Surface Areas LINE Vol (ft3 ) Area(ft 2 ) area of horizontal piping only.

MS A 268 180.68 MS B 268 180.68 For Elemental iodine Deposition LINE Vol (ft3) Area(ft 2 ) For Elemental iodine - includes total piping area and volume.

MS A 268 568 MS B 268 568 Associated Containment Leak Rate (cfh) = CPS MSIVs are tested at the Pa of 9 psig. Leak Rates are determined per standard Leak Rate Leak Rate Acceptance Criterion (scfh)

• 10CFR50 Appendix J practice for all PCIVs.

[1 4.71(Pa+1 4.7)1*(233+460)/(68+460) where Pa - 9 psig and 233 OF is peak drywell temperature at 2 minute, per USAR Figure 6.2-3.

Leak Rates LINE (scfh) (cfh) (cfm)

MS A 100 81.41 1.357 MS B 100 81.41 1.357 Fluid Temperature for 550 OF from 0 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> The deposition velocities, resuspension rates and fixation rates are temperature dependent.

deposition velocity and flow 410 OF from 24 to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> Outboard flow rates are also temperature dependent. Credit for temperature reductions in rate assessments 200 OF from 96 to 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> the current CPS AST LOCA analysis are very limited and conservative. The full normal operating pipe wall temperature is used for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The value applicable at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is used from then until 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, and the 96-hour value is used from then until 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />. The generic BWR cooldown curve has been found applicable to CPS, and the impact of decay heat from deposited radioactivity on steam piping has been found to be negligible.

Inboard Piping Node Flow LINES Flow Rate (cfm) Values are as determined from Containment Leak Rate.

Rate MS A 1.357 MS B N/A broken Outboard Piping Node Flow LINES Flow Rate (cfm) Values are conservatively expanded based on outside pressure with Fluid Temperatures at Rate 0-24 hours conservative pipe wall temperatures for the accident duration, compared with standard MS A 3.188 conditions at 68 OF. Therefore, inboard flow rates are multiplied by:

Clinton AST Parameters Page 19of27 8/18/2005 Table 6: Clinton AEB 98-03 Parameters and Methods Used for MSIV Leakage Analysis AEB 98-03 Parameters Final Supplemented Value or Method and Methods Used for Used In Justification MSIV Leakage Analysis Current AST Analysis MS B 3.188 24-96 hours 100 scfh

• 1 hr / 60 min * (550+460)/(68+460) = 3.188 cfm for 0-24 hours MS A 1.747 100 scfh

• 1 hr /60 min * (410+460)/(68+460) = 1.747 cfm for 24 to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> MS B 1.747 100 scfh

• 1 hr/60 min * (200+460)/(68+460) = 1.325 cfm for 96 to 720hours96-720 hours MS A 1.325 MS B 1.325 Leak Rate and flow rates Leak Rates and flow rates are assumed MSIV leakage is assumed to be reduced to a conservative 63.6% of the technical after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to be reduced to 63.6% of initial values specification value at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, based on the following square root leakage rate correlation after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. No further reductions with containment pressure, MSIV leakage testing performed at the CPS Pa of 9 psig, and are taken between 24 and 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />. CPS-USAR Figure 6.2-6a indicating a containment pressure of approximately 18.33 psia (3.63 psig) is reached at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for minimum ECCS in operation:

(3.63 / 9)0°5 = 0.636 Seismic Design of Credited Credited MS piping is that piping which Piping and components from the reactor vessel to the outside of the shutoff valve in the Piping has been designed to withstand a steam tunnel are Seismic Category 1 and safety related due to their functions. Downstream design basis SSE. piping through the wall between the Auxiliary Building and the Turbine Building (secondary containment boundary wall) is also seismically analyzed to assure secondary containment gas control boundary integrity. Therefore, all of this piping is available for aerosol gravitational settling or elemental iodine deposition.

Clinton AST Parameters Page 20 of 27 8/18/2005 Table 7: Clinton Parameters for FWIV Piping Deposition Parameters for FWIV Final Supplemented Value or Method Justification Used In Piping Deposition Current AST Analysis Feedwater Leakage The function of the FWLC mode of RHR Leakage limits are 10.98 cfm of containment air prior to fill, and its equivalent of 2 gpm of Control Mode (FWLC) is to create a water seal at the outboard water leakage after fill. Maximizing all flow through one of the lines minimizes piping function, and Leakage feedwater isolation check valves and deposition credit during the one-hour fill period. After fill the 2 gpm is treated as ECCS Distribution gate valves within one hour following a leakage outside of containment.

DBA LOCA and maintain the seal for a 30 day period. (USAR Sec. 5.4.7.1.1.6)

Nodalization for AEB-98-03 Two-node treatment is used for the air Outboard FWIV failure is selected since this maximizes the volume of piping in which the well mixed modeling; leakage through the feedwater line fluid is depressurized. This in turn minimizes deposition.

Single Active Failure where flow is postulated. The first node Assumptions is from the reactor vessel to the inboard A feedwater line break is not postulated because of the short duration of assumed FWIV. The second node is from the containment air leakage through feedwater lines compared to the full-accident duration of the inboard FWIV to the secondary main steam line break.

containment boundary wall.

The Outboard FWIV is assumed to fail.

Actual Inboard Piping For Aerosol Settling For Aerosols - only includes horizontal piping. Settling area is projected horizontal surface Volumes and Surface LINE Vol (ft3 ) Area(ft 2) area of horizontal piping only.

Areas FW A 57 64.56 For Elemental Iodine Deposition For Elemental iodine - includes total piping area and volume.

LINE Vol (ft3) Area(ft 2)

FW A 83 316 Outboard Piping Volumes For Aerosol Settling For Aerosols - only includes horizontal piping. Settling area is projected horizontal surface and Surface Areas LINE Vol (ft3) Area(ft 2 ) area of horizontal piping only.

FW A 182 157.82 For Elemental Iodine Deposition For Elemental iodine - includes total piping area and volume.

LINE Vol (ft3) Area(ft2)

FW A 182 496 Seismic Design of Credited Credited piping is seismically designed Piping and components from the reactor vessel to the outside of the outboard gate valves Piping from the reactor vessel through the (1B21 -FO65A/B) in the steam tunnel are Seismic Category 1 and safety related due to their containment and auxiliary building. No functions. Downstream piping through the wall between the Auxiliary Building and the turbine building piping is credited. Turbine Building is also seismically analyzed to assure secondary containment gas control boundary integrity. Therefore, all of this piping is available for aerosol gravitational settling or elemental iodine deposition.

Clinton AST Parameters Page 21 of 27 8/18/2005 Table 7: Clinton Parameters for FWIV Piping Deposition Parameters for FWIV Final Supplemented Value or Method Piping Deposition Used in Justification Piping DepositionCurrent AST Analysis ____________________________________

Associated Containment LINE (cfm) CPS FWIVs are tested with water at 1.1 times the Pa of 9 psig. Air Leak Rates are Leak Rate FW A 10.98 determined per calculated correlation to a 2qpm liquid leak rate.

Fluid Temperature for 420 OF The normal operation feed water temperature is used for the short air leakage period.

deposition velocity and flow rate assessment Inboard Piping Node Flow LINES Flow Rate (cfm) Values are as determined from Containment Leak Rate Rate FW A 10.98 Outboard Piping Node LINES Flow Rate (cfm) Values are conservatively expanded based on outside pressure with containment at Pa and Flow Rate FW A 29.50 Fluid Temperature at 420 OF for the accident duration, compared with standard conditions at 68 OF. Therefore, inboard flow rates are multiplied by:

(14.7+9)/(14.7) * (420+460)/(68+460) = 2.687 Leak Rate and flow rates No reductions in FWLC system related Leak rates are controlled by RHR system pressures rather than containment pressures, and after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> leak rates are credited. are, therefore, not assumed to be reduced with time.

Clinton AST Parameters Page 22 of 27 8/18/2005 Table 8: Clinton Parameters for Purge Piping Deposition ParametersPaaeesfrPreUsed for Purge Final Supplemented ValueIn or Method Justification Piping Deposition Current AST Analysis Leakage Distribution 100% through Purge Penetration 101 Leakage limit is, 2% La, per purge line.

100% through Purge Penetration 102 Nodalization for AEB-98-03 A one-node treatment is used for the air This treatment also conservatively ignores the impact of piping within secondary well mixed modeling; leakage through the purge lines. The containment to the intake and exhaust points. If that piping should (seismically) fail then this Single Active Failure node is conservatively assumed to be releases would be SGTS filtered. These two 2% portions of La will continue to be accounted Assumptions from containment to the outboard for in the 92% of containment leakage that is SGTS filtered, as well as being treated as a isolation valve. separate bypass pathway with aerosol settling and elemental iodine deposition credit. In effect the same activity is released through two pathways.

Piping Volumes and For Aerosol Settling For Aerosols - only includes horizontal piping. Settling area is projected horizontal surface Surface Areas LINE Vol (ft3 ) Area(ft 2 ) area of horizontal piping only.

Purge Pene. 101 373 165.04 Purge Pene. 102 330 146.07 For Elemental Iodine Deposition LINE Vol (ft3) Area(ft 2 ) For Elemental iodine - includes total piping area and volume.

Purge Pene. 101 373 518.00 Purge Pene. 102 349 486.00 Seismic Design of Credited Credited piping is seismically designed Credited piping and components are Seismic Category 1 and safety related due to their Piping from the reactor vessel through the functions.

containment and auxiliary building. No turbine building piping is credited.

Associated Containment CPS isolation valves are tested at a Pa of 9 psig.

Leak Rate = (Total Primary Containment Volume)

• 0.02

• La %/day / 1440 min/day

= 1.754E+06 ff9

• 0.02

• 0.0065 /

1440 = 0.1583 cfm LINES Flow Rate (cfm)

Purge Pene. 101 0.1583 Purge Pene. 102 0.1583 Piping Node Flow Rate LINES Flow Rate (cfm) To correct for upstream pressure conditions, 0.16 scfm is multiplied by:

Purge Pene. 101 0.3351 ((14.7psia+9psig)114.7psia)*(233eF+ 460 0R)/(68 0 F+460 0R)

Clinton AST Parameters Page 23 of 27 8/18/2005 Table 8: Clinton Parameters for Purge Piping Deposition Parameters for Purge Final Supplemented Value or Method Pping Deposition sed In Justification Current AST Analysis Purge Pene. 102 0.3351 Therefore the flowrate becomes 0.3351 cfm.

Fluid Temperature for flow 233 OF Based on peak drywell temperature (per USAR Figure 6.2-3) at the 2 minute time of post-rate assessment LOCA gap release.

Leak Rate and flow rates Leak Rates and flow rates are assumed Purge leakage is assumed to be reduced to a conservative 63.6% of the technical after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to be reduced to 63.6% after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. specification value at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, based on the following square root leakage rate correlation with containment pressure, Purge leakage testing performed at the CPS Pa of 9 psig, and CPS-USAR Figure 6.2-6a indicating a containment pressure of approximately 18.33 psia (3.63 psig) is reached at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for minimum ECCS in operation:

(3.63 / 9).5 = 0.636

Clinton AST Parameters Page 24 of 27 8/18/2005 Table 9: Clinton Tech Spec Changes Since 04/03/03 Submittal (Affected Pages)

Tech Spec Changes Final Supplemented Tech Tech Spec Changes -Submitted In Spec Changes for Current Justification for Change Comments (Affected Pages) April 3, 2003 Submittal AST Application 1.0-2 No Changes since 04/03/03 3.1-20 No Changes since 04/03/03 3.3-59 No Changes since 04/03/03 3.6-19 3.6.1.3.9 Verify leakage rate 3.6.1.3.9 Verify leakage rate Supported by design basis Changes resulted from through each MSIV leakage through each MSIV leakage analysis. recalculation based on RAls and path is s 100 scfh when path is s 100 scfh when 07/14/05 Exelon meeting with NRC.

tested at : Pa and the tested at 2 Pa and the combined leakage rate for all combined leakage rate for all MSIV leakage paths is < 250 MSIV leakage paths is < 200 scfh when tested at 2 Pa. scfh when tested at 2 Pa.

3.6-19a No Changes since 04/03/03 3.6-26 No Changes since 04/03/03 3.6-27 No Changes since 04/03/03 5.0-12 ESF Ventilation System ESF Ventilation System Change being withdrawn Supported by design basis Penetration values changed Penetration values consistent with the discussion analysis.

to: changed back to original in the 7/14/05 Exelon/NRC values: meeting and RG 1.52, Rev.2.

SGTS: 1.5%

CRV M/U: 1.5% SGTS: 0.175%

CRV Recirc: 15% CRV M/U: 0.175%

CRV Recirc: 6%

Table of Contents, No Changes since 04/03/03 Page iv Table of Contents, No Changes since 04/03/03 Page v B 3.1-38 No Changes since 04/03/03 .

B 3.1-39 No Changes since 04/03/03 B 3.1-40 No Changes since 04/03/03 B 3.1-43a No Changes since 04/03/03 B 3.3-157 No Changes since 04/03/03 B 3.6-25 No Changes since 04/03/03 B 3.6-27 Combined MSIV leakage Combined MSIV leakage Supported by design basis for all four lines changed for all four lines changed analysis.

Clinton AST Parameters Page 25 of 27 8/18/2005 Table 9: Clinton Tech Spec Changes Since 04/03/03 Submittal (Affected Pages)

TechSpe Chages Final Supplemented Tech Tech Spec Changes Submitted in Spec Changes for Current Justification for Change Comments (Affected Pages) April 3, 2003Sumta AST Application Submittal to 250 scfh, 100 scfh max to 200 scfh, 100 scfh max (TS 3.6.1.9) any one line any one line B 3.6-28a No Changes since 04/03/03 B 3.6-44 No Changes since 04/03/03 B 3.6-45 No Changes since 04/03/03 B 3.6-46 No Changes since 04/03/03 B 3.6-47 No Changes since 04/03/03 B 3.6-88 No Changes since 04/03/03 _

B 3.7-16 INSERT F INSERT F Supported by design basis This testing ensures that This testing ensures that analysis the Inleakage through the the inleakage through the negative pressure portion negative pressure portion of the Control Room of the Control Room Ventilation System Ventilation System remains within the design remains within the design basis accident analysis basis accident analysis basis. This Inleakage basis. This inleakage would be filtered by the would be filtered by the Control Room Ventilation Control Room Ventilation System recirculation System recirculation filters. An additional filters. An additional allowance of 600 cfm of allowance of 144 cfm of unfiltered Inleakage is also unfiltered Inleakage considered In the design (assuming the maximum basis accident analysis. allowed filtered Inleakage of 650 cfm) is also considered in the design basis accident analysis.

Filtered and unfiltered Inleakages can be Interchanged based on the equivalency formula provided In the design basis analysis.

Clinton AST Parameters Page 26 of 27 8/18/2005 Table 10: Summary of Clinton LOCA Dose Re-Analysis EAB LPZControl EAB LPZRoom (rem (rem ( Case) Dose Contributor TEDE) TEDE) (rem Ce) 2.853 1.029 0.944 Filtered Primary Containment Leakage (unfiltered for 10 minutes, SGTS filtered thereafter)

_____ ____[92% of LA]

4.976 0.990 0.501 PC Leakage bypassing Secondary Containment, with no piping deposition credit [8% of LA]

4.764 1.478 0.814 MSIV Leakage, without LCS but with piping deposition credit. [200 scfh total all MS lines, 100 4.764 scfh maxiline]

2.655 3.351 1.609 FWIV LCS Leakage of ECCS Water (unfiltered) [2.0 gpm]

1.646 0.166 0.081 FWIV Air Leakage before fill with ECCS Water by LCS (unfiltered) [10.98 cfm, analogous to 2.0 0.039 0.066 0.033 Primary Containment Leakage through purge penetrations 101 and 102, with piping deposition 0.03 0.66 0033credit [2% of La per penetration]

0.174 0.196 0.136 ECCS Leakage in Secondary Containment (unfiltered for 10 minutes, SGTS filtered thereafter)

N/A N/A 0.585 Gamma Shine to Control Room 17.11 7.28 4.70 Total Calculated Value 25 25 5 Dose Limit

Clinton AST Parameters Page 27 of 27 8/18/2005 Table 11: Summary of Clinton MSLB Dose Re-Analysis Control.

EAB LPZ Room (rem TEDE) (rem TEDE) (RoA Case) Analyzed Case

._ (rem TEDE) 2.47E-02 6.88E-03 8.31 E-02 Case 1: Normal Equilibrium of 0.2 pCi 4.90E-01 1.36E-01 1.66E+00 Case 2: Iodine Spike of 4.0 gCi Case 1: 2.5 Case 1: 2.5 Case 1: 5 Dose Limits Case 2: 25 Case 2: 25 Case 2: 5 Table 12: Summary of Clinton CRDA Dose Analysis (Un hanged by this S pplement)

Control EAB LPZ Room (rem TEDE) (rem TEDE) (1DBA Case) Analyzed Case (rem TEDE) 4.1 -02.6E-2 4.E-01 Case 1: Based on 1%of condenser free volume 4.1 E-02 1.6E-02 4.3E-01 leakage per day 6.4E-01 1.5E-01 2.5E-01 Case 2: Based on steam jet air ejector activity 6.3___ 6.3__ 5Drelease 6.3 6.3 5 Dose Limits

ATTACHMENT 3 Markup of Proposed Technical Specifications Page CLINTON POWER STATION FACILITY OPERATING LICENSE NO. NPF-62 Markup of Proposed Technical Specifications Page 3.6-19

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued) eD SURVEILLANCE FREQUENCY SR 3.6.1.3.8 ------------------NOTE-----------------

Only required to be met in MODES 1. 2.

and 3.

Verify the combined leakage rate for all In accordance secondary containment bypass leakage with the paths is

• 0.08 La when pressurized to Primary Containment 2 Pa Leakage Rate Testing Program SR 3.6.1.3.9 ------------------NOTE------------------

Only required to be met in MODES 1, 2, and 3.

verify t 1 lea e rate rou 1 In accordance four in st line <S en with the 04~ /sted a_ _ , Primary Containment Leakage Rate I Testing Program SR 3.6.1.3.10 ------------------NOTE------------------

Only required to be met in MODES 1. 2, and 3.

Verify combined leakage rate through In accordance hydrostatically tested lines that with the penetrated the primary containment is Primary within limits. Containment Leakage Rate Testing Program w11 I\4e4e (cotinued)

<< WOO S:Gk w4 4e&^ci aA cwgoatd4LXe CavvLned L~ale vmu~

f ( Rst VLL e Has Is z coo t'sS iA Bv4es4eJ a0 >l.

CLINTON 3.6-19 Amendment No. 145

ATTACHMENT 4 Retyped Technical Specifications Page CLINTON POWER STATION FACILITY OPERATING LICENSE NO. NPF-62 Retyped Technical Specifications Page 3.6-19

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.8 ------------------NOTE------------------

Only required to be met in MODES 1, 2, and 3.

Verify the combined leakage rate for all In accordance secondary containment bypass leakage with the paths is < 0.08 La when pressurized to Primary 2 Pa. Containment Leakage Rate Testing Program SR 3.6.1.3.9 ------------------NOTE------------------

Only required to be met in MODES 1, 2, and 3.

Verify the leakage rate through each MSIV In accordance leakage path is < 100 scfh when tested at with the 2 Pa and the combined leakage rate for Primary Containment all MSIV leakage paths is < 200 scfh when Leakage Rate tested at Ž Pa- Testing Program SR 3.6.1.3.10 ------------------ NOTE------------------

Only required to be met in MODES 1, 2, and 3.

Verify combined leakage rate through In accordance hydrostatically tested lines that with the penetrated the primary containment is Primary within limits. Containment Leakage Rate Testing Program (continued)

CLINTON 3.6-19 Amendment No.

ATTACHMENT 5

-- Markup of-Proposed-Technical-Specification-Bases Page Markup of Proposed Technical Specification Bases Page (Provided for Information Only)

B 3.6-27

PCIVs B 3.6.1.3 BASES

1) SURVEILLANCE REQUIREMENTS SR 3.6.1.3.8 (continued) leakage through the isolation device. If both isolation valves in the penetration are closed, the actual leakage rate is the lesser leakage rate of the two valves. This method of quantifying maximum pathway leakage is only to be used for this SR.

The Frequency is consistent with the Primary Containment Leakage Rate Testing Program. This SR simply imposes additional acceptance criteria. Secondary containment bypass leakage is considered part of La.

A Note is added to this SR which states that these valves are only required to meet this leakage limit in MODES 1, 2 and 3. In the other conditions, the Reactor Coolant System is not pressurized and specific primary containment leakage limits are not required.

With regard to leakage rate values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. 9)..

SR 3.6.1.3.9 The analyses in-References 1, 2, and 3 are ased on leakage that is less than the specified leakage rate. leakage I through all four main steamlines must be c when tested at P. (9.0 psig).J The MSIV leakage rate must be verified to be in accordance with the assumptions of References 1. 2, and 3. A Note is added to this SR which states that these valves are only required to meet this leakage limit in MODES 1, 2, and 3. In the other conditions, the Reactor Coolant System is not pressurized and primary containment leakage limits are not required.

The Frequency is required by the Primary Containment Leakage Rate Testing Program.

(continued)

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)

CLINTON B 3.6-27 Revision No. 7-2